"I was just pointing out that there are restrictions to the practice if torture or extreme cruelty is involved. Most of the convictions I've heard about involved satanic rituals. "
Funny. Getting killed seems pretty cruel to me. Now, suppose you find a single conviction for me involving sacrifice and satanic rituals. I'm sure you've heard of some, but I challenge you to find them and report back, with legitimate sources.
I've found an example of the particular law I was referring to on the Association of the Bar of NYC's website.
Here are the relevent portions (and link for complete citation):
A religious purpose is not a justification for cruelty, so a religiously neutral cruelty statute such as § 353 may be enforced to prohibit ritual animal sacrifice.[5] Similarly, freedom of speech is not a justification for cruelty, so § 353 may be enforced to prohibit cruelty even where such cruelty was committed with an expressive purpose.[6] Moreover, the New York cruelty statute does not exempt animal husbandry practices. Thus, although the slaughter of animals in accordance with humane slaughter lawsa [7] would not violate the cruelty statute, abuse or neglect of farm animals that is not otherwise sanctioned by law is prohibited.[8] And acts that are ordinarily lawful, such as whipping a racehorse, may become unlawful when they are done to excess.[9]
footnotes:
[5]Church of the Lukumi Babalu Aye v. Hialeah, 508 U.S. 520 (1993) (a statute enacted with the legislative purpose of banishing or repressing a particular religious group is unconstitutional, whereas a neutral statute may incidentally restrict religious practice).
from:
http://www.abcny.org/cruelty.htm The florida case you referred to is mentioned in the footnote. The majority opinion in that case (written by Kennedy) struck down the Hialeah ordinance as being unconsitiutional due to the narrowness of it's application to religious groups. Animal cruelty laws not solely designed to constrict religious practice may be enforced.
Here is one example of someone convicted of cruelty to animals in a satanic mutilation case. Althought I wouldn't describe it as a "sacrifice" because the animals weren't killed.
from
http://www.petfinder.org/journalindex.cgi?path=private/shelteroperations/petprotectors/humanearizona/2.62.107.txt In southern Arizona, law enforcement often suspect that dabblers are present if animal mutilations are found in close proximity with other telltale signs candle drippings, strange symbols, non-discernable alphabets, vandalized religious artifacts, etc. One of the most recent animal cruelty cases to have ritualistic overtones were the horse mutilations at the Fred Fry Stables on August 9, 2000. Tucson Police and Pima County Sheriffs Department personnel noticed strange symbols cut into the skin of some mutilated horses. James Hart and Syljva King, both convicted in March 2001 of the crimes, reportedly told authorities that they practiced their own version of Satanism.